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expert’s conclusions as to the value of the property as of the
contribution date.
D. Assessed Value of Subject Property
We now address the assessed value of the subject property.
The assessed valuation of property is also evidence of the
property’s value where, as is the case in Nebraska, the assessed
value is defined as the property’s fair market value. See N.
Trust Co. v. Commissioner, 87 T.C. 349, 382 (1986); Neb. Rev.
Stat. sec. 77-112 (1996 & Supp. 2000). Assessed valuation may be
used to corroborate fair market value determined under the three
traditional approaches. See N. Trust Co. v. Commissioner, supra.
Here, the Antelope County assessor determined that the
assessed value of the subject property for 1998 was $70,424. The
assessment took into account physical depreciation, economic
obsolescence, and functional obsolescence in valuing the
property.
We place great weight on the assessed value of the subject
property because it corroborates the actual sale and the
valuation of respondent’s expert as indicators of the fair market
value of the subject property. This unrelated third party
valuation, close to the values in the prior sale and determined
by respondent’s expert, reinforces our view that the purchase
price of the property is persuasive evidence of its true fair
market value.13
13Petitioners contend that the value the Antelope County
assessor determined is somehow biased and the assessor was simply
(continued...)
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